Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic - February 2021
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Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic February 2021
Contents 1 Motivation 3 2 Conceptual and monitoring framework 5 2.1 The COVID-19 shock and its transmission to the real economy and the financial sector 5 2.2 Cross-border implications 12 2.3 Cross-sector implications 14 3 Data sources used for monitoring 15 4 Financial stability implications of fiscal measures 17 4.1 Drivers of fiscal measures 17 Box 1 Preliminary evidence from AnaCredit on new lending to NFCs during the COVID-19 pandemic 25 4.2 From liquidity to solvency problems 29 Box 2 Identification of delayed structural change associated to the assessment of firms’ viability 31 4.3 Transparency of balance sheet information 32 Box 3 Challenges in credit risk modelling for accounting and prudential purposes 35 4.4 Cliff effects 36 5 Key findings and policy priorities 39 Annex A – Monitoring indicators 46 Annex B – Data on fiscal measures 52 B.1 Types of fiscal measures 53 B.2 Amounts of fiscal measures 55 B.3 Moratoria on loans 58 B.4 Public guarantees on loans 61 B.5 Public loans 63 B.6 Direct grants 65 B.7 Tax deferrals and reliefs 67 Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Contents 1
B.8 Equity participations 69 B.9 Public support for trade credit insurance 70 B.10 Timeline of expiry as of 30 September 2020 71 B.11 Summary of the qualitative assessment of the third quarter of 2020 72 References 74 ESRB Working Group members 76 Imprint and acknowledgements 77 Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Contents 2
1 Motivation 1 The ESRB Working Group on monitoring financial stability implications of fiscal measures to protect the real economy in the context of the coronavirus (COVID-19) pandemic (henceforth, the WG) was established in June 2020 under the auspices of the General Board. It builds on the work of a related ad hoc ESRB Steering Committee Workstream. It was mandated to develop a regular EU-wide monitoring of the financial stability implications arising from the temporary measures that governments have put into place in response to the COVID-19 pandemic, with a focus on cross-border and cross-sectoral implications. This report summarises the work conducted and was approved by the ESRB General Board on 15 December 2020. The pandemic has intensified risks and vulnerabilities in the real economy, but prompt action by governments has provided crucial relief to households and non- financial corporations (NFCs). Fiscal measures such as loans with public guarantees and direct grants have helped to prevent the loss of viable businesses and contain the impact of the pandemic. Moratoria schemes have also been providing liquidity support during the health emergency. So far, backed by government support, monetary policy and regulatory easing, the financial system has continued to provide funding to the real economy and losses in banking books have been contained. However, the financial stability implications still need to be monitored. This Report provides a framework for monitoring financial stability implications of the measures and illustrates some initial results and policy findings. The Working Group proceeded in four stages. First, it developed a conceptual monitoring framework to analyse the financial stability implications of fiscal measures. Core to this framework are the transmission channels of the fiscal measures in terms of solvency and liquidity issues in the real economy and therefore the ability of these measures to shield the financial sector from the effects of the pandemic. Because these fiscal measures were mostly transmitted through the banking system, this channel was the focus of the report. Section 2 describes this framework. Second, based on these transmission channels the Working Group derived a set of key indicators to monitor the financial stability implications of the fiscal measures put in place during the pandemic. These will serve as a basis for the ESRB’s quarterly monitoring. A longer list of supplementary indicators may complement this at national level. The Working Group explored information collected directly by the ESRB, as well as from the EBA and the ECB. A description of these indicators is provided in Section 2 and Annex A. Section 3 describes the data sources used. Third, the Working Group identified and started analysing key issues relevant to monitoring financial stability implications in more depth. It started to describe how the drivers of fiscal programmes are related to the structure and to the vulnerability of the real economy and the financial system to the COVID-19 pandemic. Then it focused on the solvency and liquidity of 1 The report uses the term “fiscal measures” in a broad sense as it also provides information on measures such as loan moratoria which do not have direct fiscal implications. Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Motivation 3
borrowers and the implications for credit markets and the solvency of the financial sector. It also elaborated on the quality of balance sheet information, as there is a time lag before borrowers’ vulnerabilities have an impact on banks’ balance sheets. The report further considered the potential cliff effects related to the expiry of fiscal measures that warrant attention from the authorities. Section 4 details these issues. Fourth, key findings and policy priorities are summarised at the end of this report. Based on this initial monitoring work, the WG has now completed its mandate. Going forward, the ESRB will continue with regular monitoring, based on the indicators and transmission channels identified. Relevant analytical topics will be addressed in future work including, in particular, the analysis of cross-sectoral and cross-country spillovers. So far these have been contained by the fact that the COVID-19 shock has not been transmitted in full to the financial sector. However, such spillovers may become more important in future adverse scenarios. Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Motivation 4
2 Conceptual and monitoring framework This section provides a high-level overview of the financial stability implications stemming from the COVID-19 shock and the policy response to it. It discusses how fiscal measures to support the economy during the pandemic interacted with the financial sector to mitigate the immediate financial stability implications of the shock. It proposes a set of indicators to monitor the exposure of households, firms and financial intermediaries to risks stemming from the COVID-19- shock. 2.1 The COVID-19 shock and its transmission to the real economy and the financial sector Figure 1 illustrates how the COVID-19 shock affected the liquidity and solvency of non- financial firms and households, the policy measures adopted to mitigate this, and the impact these had on the financial system. It also displays the policy measures that affect the financial sector directly and the potential feedback effects that may occur if the financial system becomes stressed. These effects can be amplified through cross-sectoral and cross-border transmission channels. The graphic distinguishes between the direct impact on firms and households and the indirect impact on the financial sector that may occur when the loss absorption capacity of firms and households is depleted. Figure 1 Transmission mechanisms of financial stability implications of fiscal measures Covid-19 shock Policy measures affecting liquidity Policy measures affecting • Monetary, fiscal, regulatory Non-financial firms liquidity policies Financial system and households • Cash flow • Cash flow Policy measures • Balance sheets Policy measures affecting solvency • Balance sheets affecting • Capital measures solvency • Recovery & Resolution • Forbearance Government Credit and financial conditions Cross-border and cross-sectoral issues Source: ESRB. The figure distinguishes three different sectors: private non-financial sector (non-financial firms and households), financial sector (banks and other non-bank financial intermediaries) and public sector. Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Conceptual and monitoring framework 5
The degree to which the shock is transmitted through each of these depends on three factors detailed in Table 1: 1. resilience in terms of vulnerabilities or financial absorption capacity; 2. shock exposure in terms of the magnitude of the shock hitting a particular sector; 3. policy measures and their effectiveness in terms of cushioning the shock and/or enhancing resilience. Table 1 Factors influencing the impact of the COVID-19 shock Resilience (vulnerability) Shock exposure Policy measures Non-financial Sector of economic activity Decline in demand due to Fiscal measures to protect firms Financing structure lockdown and precautions liquidity and solvency, including Structural change in demand loan moratoria, public guarantees Degree of internationalisation and public loans Degree of digitalisation Disruption of value chains Net worth and liquidity reserves Cost of compliance with public health measures Access to credit and capital Physical proximity needed to do business Households Occupation Decline in employment and Fiscal measures to protect Debt level and debt service to wages liquidity and solvency, including income measures to support employment, direct grants to Net worth, composition of assets support income and loan held and liquidity reserves moratoria Banks Sectoral exposure of portfolios Increased credit risk Supervisory, regulatory and Maturity or liquidity mismatch Losses on securities held accounting measures Leverage Increased funding costs Use of capital and liquidity buffers Profitability before the pandemic Operational risks, including Monetary policy measures Credit quality cybersecurity Size of capital buffers Non-bank Sectoral exposure of portfolios Increased credit risk Supervisory measures intermediaries Maturity or liquidity mismatch Losses on securities held Monetary policy measures Leverage Increased funding costs Profitability Lapses in insurance contracts/loss of business National Debt levels Lower tax revenue External funding (European or governments* Debt service Increased spending international bodies) Increased refinancing costs Monetary policy Structural measures to enhance growth Note: * Although National governments are impacted by COVID-19, any medium-term in-depth discussion of these implications goes beyond the scope of the Working Group, as well as a discussion of monetary policy. The transmission mechanisms feature a feedback loop from credit and financial conditions to the real economy. If the magnitude of the shock (i) cannot be absorbed by the resilience of non- financial firms and households and/or (ii) is not sufficiently mitigated by policy measures, the Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Conceptual and monitoring framework 6
financial sector might be severely affected, potentially becoming unable or unwilling to provide credit, liquidity and financial services to the economy. In this situation the financial sector could exacerbate liquidity and solvency problems in the real economy, eventually creating a doom loop between the real economy and the financial system. The COVID-19 shock The COVID-19 pandemic is fundamentally affecting economies around the world. Households and firms have adjusted voluntarily to the risk of uncontrolled spread of the virus by maintaining social distancing and reducing activities with a high infection risk. In an attempt to contain the spread of the virus and slow the pandemic, governments have implemented measures that substantially limit mobility and severely restrict economic activity. There is high uncertainty with regard to the magnitude and duration of the shock. Despite the strong rebound in economic activity seen in the third quarter of 2020, the new waves of COVID-19 infections in the EU and the concomitant increase in the stringency of containment measures mean that the path to economic recovery is highly uncertain. At the same time, the fact that COVID-19 vaccines have become available has lowered the risk of more severe scenarios. Containment measures and changes in behaviour have led to a sharp reduction in economic activity. Demand for non-essential goods and services has dropped. The service sector was strongly affected, in particular segments such as restaurants and travel, but the fallout from the pandemic and the containment measures were not limited to this sector. Disruptions in supply are accompanying the decline in demand. Border closures and disruption to the production of intermediate goods and transportation have caused a severe supply shock. These have had a particularly large impact on sectors that are closely integrated in global supply chains. The effects of the pandemic on the real economy are therefore very heterogeneous. For the purpose of this work, the severity of the shock and its impact on member countries is best captured by a simple and straightforward measure of lost economic output. The summary indicator to be monitored is: • Foregone GDP as a percentage of pre-crisis forecasts. This compares the pre-crisis GDP forecast (the European Commission’s winter 2020 forecast is taken as the benchmark) with actual post-crisis GDP or the post-crisis forecast. The difference between the two provides a basis for drawing inferences about the severity of the shock. • Sectoral exposure. Information on the aggregate effects of the shock on GDP can be supplemented with information on changes in sectoral output or employment or other information capturing sectoral shock exposure. Effects on non-financial firms and households Non-financial firms in sectors hit by the pandemic are facing a sharp reduction in cash inflows and losses. Lower demand for goods and services suppresses sales and increases Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Conceptual and monitoring framework 7
demand for short-term liquidity. The resilience/vulnerability of firms prior to the COVID-19 shock affects the strength of the necessary adjustments and the effect on their solvency. The stronger firms’ balance sheets are in terms of equity and liquidity reserves, the longer they can withstand the decline in cash flows and absorb losses. Hence, firms’ net worth is a buffer that prevents the further propagation and amplification of shocks. Different firms and sectors entered the crisis with different balance sheet positions, which affects their vulnerability to the shock. Moreover, the high degree of uncertainty about economic developments hinders investment decisions. Households have been affected as firms have reduced wages or laid off workers, with negative implications for household income and net worth. The vulnerability of individual households depends on occupation and balance sheet/liquidity strength. Given the risk of job losses and expectations of a difficult financial situation, households may further restrict demand for goods and services and increase precautionary savings. This would reinforce the initial impact of the pandemic on firms, leading to further layoffs and company closures. Over time, the crisis could also affect the solvency of households and their capacity to absorb losses. The effects of the pandemic on firms and households depend on their cash buffers and ability to absorb losses. Risk indicators such as insolvencies of NFCs and the level of non- performing loans (NPLs) typically lag the actual shock because policy measures delay the moment the risk materialises. For the purposes of this work, the effects on firms and households will be monitored using the following liquidity and solvency indicators. • The number of NFC insolvencies relative to pre-crisis levels measures the materialisation of risk in this sector, with possible contagion to the household and financial sectors. • The percentage of credit lines to NFCs undrawn gives information about the liquidity buffers NFCs can use if adverse conditions persist or deteriorate. • NFCs’ debt to equity ratio shows leverage and the vulnerability of NFCs to future shocks. • Household debt as a percentage of pre-crisis net disposable income shows the vulnerability of households to future shocks. • The percentage change in banks’ stock of loans to NFCs shows the flow of credit to NFCs. • The percentage change in banks’ stock of loans to households shows the flow of credit to households. • The growth in banks’ sectoral loan volumes to NFCs operating in the sectors most affected shows the flow of credit to the most vulnerable sectors. Direct effect on the financial system At the onset of the pandemic, the functioning of the financial system was at risk. High uncertainty about the further course of the pandemic led to a significant collapse in asset values and a sharp deterioration in financing conditions. The slump in cash inflows led to short-term liquidity shortages. Uncertainty over whether the financial system would be ready to provide firms Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Conceptual and monitoring framework 8
and households with funding through credit lines or loans was high. Surging spreads and tighter financial conditions indicated that some sectors might lose access to funding. There was a clear risk that firms which had run into liquidity problems could see these turn into solvency problems due to the lack of access to liquidity. This initial threat to financial stability was contained by a decisive policy response and a relatively high degree of resilience in the financial system. Fiscal policy measures have supported the liquidity and solvency of the real economy and thus, indirectly, the financial sector. Monetary policy has stabilised asset prices and maintained favourable funding conditions for banks. Moreover, the financial system was relatively resilient at the onset of the COVID-19 pandemic due to a comprehensive set of regulatory reforms implemented in the aftermath of the global financial crisis. Banks have higher capital buffers that help to absorb losses. Supervisors used the flexibility of the new regulatory framework to allow banks to draw on these buffers so they could continue lending. This was intended to reduce potential procyclicality that might stem from banks’ responses to capital regulation. For the purposes of this work, the impact of the COVID-19 shock on the financial system will 2 be monitored using the following indicators. • Gross NPLs as a percentage of total gross debt instruments provide a backward-looking view by measuring realised losses on loans. • The percentage of stage 2 loans as defined in IFRS 9 (those with increased credit risk) provides a forward-looking view of the risk in banks’ balance sheets. • Weighted average probability of default (PD) on the new NFC loan portfolio gives a more 3 sensitive forward-looking view of the risk in banks’ new lending. • The CET1 ratio measures banks’ ability to withstand future shocks and support the real economy. It can be supplemented by the leverage ratio, which is not sensitive to risk weights. • The insurers’ solvency ratio measures insurers’ ability to withstand future shocks and support the real economy. The policy response and second-round risks to financial stability Fiscal measures mitigate financial stability implications by reducing the losses suffered by households and firms and protecting their net worth. If the capacity of households and firms to absorb losses becomes insufficient, non-performing or forborne loans and defaults will increase. This risk is more likely to materialise over time if the mitigating measures are insufficient and/or if the design features of the measures are such that the uptake is insufficient. 2 The first four indicators focus on the banking sector, where the COVID-19 risks are expected to be greatest, while the fifth indicator focuses on insurance companies. 3 This indicator is available from AnaCredit only for banks using internal models. Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Conceptual and monitoring framework 9
Over the medium and longer term, however, the design features of fiscal measures could themselves create distortions, leading to second-round risks to financial stability. Some measures may increase the indebtedness of households and firms, with potential negative effects on financial stability. Others may have a positive impact on financial stability in the short run but create adverse incentives in the medium term, such as adverse selection, moral hazard and evergreening. The phasing out of fiscal measures needs to be evaluated carefully. Premature termination might trigger system-wide distress in the banking sector due to cliff effects associated with the liquidity and solvency conditions of borrowers. At the other extreme, extending fiscal measures for too long could protect firms and banks that are no longer viable, delaying their exit from the market. Prolonged financial problems for firms and households could pose a threat to financial stability. If the scale or uptake of national and EU-wide measures is insufficient, the sharp drop in economic activity could lead to write-downs in the financial sector over the medium term. Corporate insolvencies could lead to significant loan defaults. If household solvency is affected, the financial sector would also have to absorb additional losses from bad mortgages and consumer loans. Capital buffers in the financial sector may not be sufficient to cope with large-scale insolvencies in the real economy. The financial sector would have to react by reducing its balance sheet and restricting lending. Sectors could then have problems obtaining follow-up financing. In this situation, the financial system could exacerbate the economic downturn in the medium term or delay recovery. Table 2 summarises the financial stability implications of different fiscal measures over both the short term, i.e. the containment phase, and the medium term, when measures are being phased out and the economy is moving into recovery. Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Conceptual and monitoring framework 10
Table 2 Financial stability implications of measures targeting the real economy Short-term implications Phasing-out issues (containment phase) (recovery phase) Loan and insurance Avoids household/NFC defaults by easing Risk of increase in NPLs when moratoria expire premium moratoria liquidity problems Keeps unviable NFCs in business for the Worsens liquidity of the financial sector due to duration of the moratoria reduced cash inflows Public guarantee on Eases liquidity difficulties of NFCs Debt overhang due to increased firms’ leverage loans Supports lender solvency due to lower risk Risk of losses from granting new loans to weightings unviable NFCs Risk of increase in NPLs when guarantees expire Cliff effect (guarantee may be called close to expiry) Risk of losses for guarantor Moral hazard for banks Public guarantee on Eases access for NFCs to credit insurance Risk of losses for guarantor trade credit insurance Moral hazard Direct grants and Avoids NFC/household defaults by easing Direct fiscal cost employment liquidity/solvency problems Risk of keeping unviable NFCs in business measures Public/subsidised Avoids defaults by easing liquidity problems of Risk of losses from granting new loans to loans NFCs unviable NFCs Supports NFC solvency (provided loan terms Increase in firms’ leverage better than market funding) Risk of keeping unviable NFCs in business Excessive risk-taking due to mispricing of risks Equity participation Avoids defaults by easing solvency/liquidity Fiscal cost problems of NFCs Risk of keeping unviable NFCs in business Competition issues (bias towards large companies) Reduces leverage Tax deferrals and tax Eases liquidity difficulties of households/NFCs Increased cash outflows when deferred taxes relief Supports solvency of households/NFCs (tax are due relief only) Fiscal cost of tax relief Notes: Green and red implications are positive and negative respectively for financial stability in the short term. The phasing-out issues pertain to timing: too soon and risks may be triggered, too late and extensions to support programmes could lead to a build-up in vulnerabilities. The impact of policy measures and their second-round effects will be monitored using the following indicators. These focus on the most important support measures adopted in member countries so far: moratoria, public guarantees, public loans and direct grants. • Uptake of direct grants by NFCs and households as a percentage of 2019 GDP. This is a measure of solvency support for the private non-financial sector. • Uptake of public guarantees and public loans by NFCs as a percentage of 2019 GDP. These are measures of liquidity support for the private non-financial sector. Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Conceptual and monitoring framework 11
• Uptake of moratoria by NFCs and households as a percentage of 2019 GDP or total credit granted measures the impact of programmes seeking to postpone and contain a wave of loan delinquencies. • General government debt as a percentage of 2019 GDP measures the vulnerability of governments and their capacity to further support the real economy. • Loans with moratoria expiring in less than three and six months as a percentage of total loans measures the potential cliff effect when moratoria programmes are discontinued. • Loans with public guarantees expiring in less than six months as a percentage of total loans measures the potential cliff effect when public guarantee programmes are discontinued. 2.2 Cross-border implications Tight real and financial linkages can generate positive cross-border externalities and affect financial stability. General spillovers represent one channel: measures in one country can stimulate demand for imported goods and services and benefit firms with cross-border operations. Also, stabilising production at firms that are highly integrated within cross-border value chains can have positive effects on aggregate supply. Positive cross-border spillovers stimulating the economy benefit financial institutions because they tend to lower defaults by firms and households abroad. This effect can be direct, through valuations of loans or securities, or indirect, through exposures to other financial institutions serving foreign entities. Banks in Europe have large cross-border activities. Banks with international operations can therefore benefit from measures taken abroad which might have positive cross-border effects on financial stability in their home country. However, the design and timing of fiscal measures can also generate negative externalities. These need to be taken into account when timing the phasing out of fiscal measures and coordinating this across countries. Negative cross-border effects could arise through various channels. First, the effects that domestic fiscal measures have on other countries may be insufficiently reflected in domestic policy decisions. For example, policy measures targeting critical nodes in cross-border value chains may find less support in the domestic policy process than measures targeting relevant domestic constituencies. Second, in an adverse scenario banks may face higher losses and react to these by deleveraging. Such deleveraging may have a relatively greater impact on cross-border exposures than on domestic ones – countries in which foreign banks have a strong presence could see these withdrawn if the crisis worsens and the measures taken appear to be insufficient or poorly designed. Similarly, the need to support cross-border business might affect lending in the domestic economy. Third, the size and design of fiscal measures can influence the extent to which non- domestic entities are affected. This applies, for instance, with moratoria and public guarantees on loans when the lenders are mostly non-domestic or foreign-owned. The design features of loan Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Conceptual and monitoring framework 12
guarantees and different national approaches to credit insurance support might affect the regulatory 4 treatment of loans or credit insurance . An uneven playing field and regulatory arbitrage due to differences in the design features of fiscal measures might have an adverse impact on the effectiveness of national policies. Fourth, disparities across member countries can affect financial stability. Countries are being affected differently by the COVID-19 shock, and their resilience and fiscal space differ. If there is a high degree of heterogeneity across member countries in the implementation of fiscal measures, financial integration may decline, with potentially negative effects on financial stability. It is therefore important to monitor cross-border disparities and the appropriateness of these measures, including fiscal and monetary policy support at the EU level, to deal with such divergence. It should be noted that an uneven recovery makes EU policymaking less effective and more challenging to design and agree on. Indicators to monitor The evidence to date indicates that no material adverse cross-country spillovers have 5 materialised. Given the high degree of cross-border integration in Europe’s real economies and financial sectors, however, two main channels of contagion require careful monitoring: • cross-border activity of financial institutions and potential changes once measures have been introduced, in particular with regard to lending and capital allocation at cross-border groups; • trade openness and cross-border value chains that might suggest a propensity for cross- border spillovers. The methodological framework established by the ECB Task Force on Cross-border Spillover Effects of Macroprudential Measures can be informative for monitoring cross- 6 border contagion. The Task Force created a short list of indicators to monitor cross-border spillovers from macroprudential measures. In particular, capital-based indicators can also be useful for analysing spillovers from fiscal measures that operate through bank lending. Both outward spillovers (effects of fiscal measures on other countries) and inward spillovers (effects of fiscal measures introduced in other countries) are relevant. Level indicators (such as the percentage of loans granted by foreign banks) are helpful in identifying the propensity for cross-border spillovers, while change indicators (such as a decline in lending by foreign banks) might indicate that spillovers have materialised. 4 For this reason EIOPA published a Supervisory Statement recommending that NCAs apply supervisory flexibility when assessing whether schemes that have the same consequences as reinsurance may be deemed to be risk mitigation techniques under Solvency II, even where they have been implemented directly by the government rather than state insurers or credit export agencies. 5 This evidence includes the results of the July and October rounds of the qualitative questionnaire reported by national authorities to the ESRB, as mandated by Recommendation ESRB/2020/8 (template 3). 6 See Framework to assess cross-border spillover effects of macroprudential policies and Kok and Reinhardt (2020). Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Conceptual and monitoring framework 13
2.3 Cross-sector implications The COVID-19 shock and the resultant fiscal measures can have cross-sectoral implications through direct and indirect linkages. Direct interlinkages exist between financial institutions when they are direct counterparties or there is an ownership relationship. These are reflected both on-balance sheet and off-balance sheet. Indirect interlinkages relate to situations where financial institutions are exposed to common risks, such as the sectors most affected by the pandemic. If the measures taken are not sufficient to mitigate the impact of the crisis, these interlinkages may potentially interact to create systemic risks. Design features of fiscal measures can affect incentives and competition in the financial sector, with cross-sectoral implications. If, for example, loan moratoria or guarantees apply only to banks, creditors will be treated inconsistently across sectors. Over the medium term, this might distort competition due to lock-in effects in lending markets. In this situation, the risks that are likely to materialise after measures have expired might accumulate in particular sectors of the financial system and not be shared. If measures are channelled through different parts of the financial sector correlated exposure to the same risks might increase. Indicators to monitor The survey among national authorities revealed that few cross-sectoral implications are currently expected. Nevertheless, the following indicators should be monitored to identify any relevant effects: • market shares of banks and non-bank financial institutions; • inter-sectoral exposures; • common sectoral exposures. Based on this conceptual framework, Annex A provides a list of key indicators that serve as a basis for the ESRB’s quarterly monitoring, as well as a longer list of supplementary indicators that can be the basis of a monitoring framework in national authorities. These indicators can be subject to modification when more experience with the shock transmission is being gained. In any case, these indicators provide only limited information and should be complemented with any relevant qualitative and quantitative information. Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Conceptual and monitoring framework 14
3 Data sources used for monitoring The ESRB is using existing and new datasets to establish the framework for monitoring the financial stability implications of fiscal measures. One of the key principles applied in setting up the framework is to use data already collected so as not to increase the reporting burden of the financial industry. The main and most novel source of information is the results of the qualitative and quantitative questionnaires reported by national macroprudential authorities under 7 Recommendation ESRB/2020/8. This recommends that they: (A) monitor the design features and the uptake of measures and their implications for financial stability, and (B) report these design features and the uptake to the ESRB. The data gathered under Recommendation B encompass all fiscal measures relevant to financial stability, providing the most complete picture of the size, 8 uptake and design features of fiscal measures taken by ESRB member countries. The following section uses the data from this submission. The results should be interpreted with caution given the possible under-reporting of measures by some countries (in particular on uptake). The Annex B provides further detailed information about the features and the uptake of measures as reported by macroprudential authorities with a reference date of September 2020. The monitoring is also based on existing data available to the ESRB Secretariat. These include the datasets (mainly from the ECB) used to prepare the regular ESRB risk assessment. The information is supplemented by granular data requested from the ECB (AnaCredit) and the EBA (EBA COVID-19 reporting). Each dataset covers different dimensions of the financial stability implications of fiscal measures. The EBA COVID-19 reporting facilitates the monitoring of the uptake of moratoria and public 9 guarantees of loans across banks, non-financial firms and households. Data collected from banks via the EBA supervisory reporting framework provide an input which is essential to the financial stability monitoring framework. Regular EBA supervisory reporting has been temporarily extended to capture the implications of measures implemented in response to the COVID‐19 pandemic, focusing on the impact of payment moratoria and public guarantees. EBA COVID-19 reporting is submitted by banks quarterly, starting as at 30 June 2020, and is expected to continue for 18 months. Specific data points relevant to financial stability have been shared by the EBA with the ESRB. These data are already being used to develop relevant indicators, such as the percentage of exposures with public guarantees and moratoria, the take-up of measures by different economic sectors, the maturity profile, and indicators showing a possible deterioration in credit quality among exposures benefiting from the measures. 7 Recommendation ESRB/2020/8 on monitoring the financial stability implications of debt moratoria, public guarantee schemes and other measures of a fiscal nature taken to protect the real economy in response to the COVID-19 pandemic. 8 Recommendation (B) requires three reporting templates to be submitted to the ESRB, with the first submission due by 31 July 2020 and the second by 30 October 2020. These reporting templates are composed of three templates covering their features (template 1), their uptake (template 2) and a qualitative questionnaire (template 3). While the first two include information on fiscal measures taken, the third collects the main qualitative concerns of authorities regarding the implications of the measures. 9 For details see the EBA Guidelines on reporting and disclosure of exposures subject to measures applied in response to the COVID-19 crisis. Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Data sources used for monitoring 15
Another important data source is AnaCredit, which provides detailed information on 10 individual bank loans to NFCs in the euro area, harmonised across member countries. Information from a credit registry is important for three reasons. First, it makes it possible to monitor credit supply and demand and shifts in lending across different sectors of the economy and borrowers of different sizes and risk profiles. AnaCredit can provide information about changes in the characteristics of the firms and banks making use of fiscal measures. The use of granular data makes it possible to take a borrower-lender perspective, which is crucial to identifying where risks originate. Second, granular information is relevant when analysing financial stability, as it can help to identify how stress in the individual parts of the financial system can affect the system as a whole. This sort of contagion can arise from exposure at large financial institutions to idiosyncratic shocks, interconnectedness and common exposure to macroeconomic shocks. Third, AnaCredit provides information on new loans issued. Together with information from the ESRB reporting, it provides an approximation of the percentage of new loans to NFCs subject to fiscal measures. 10 For details see the ECB webpage on Anacredit and Israël et al. (2017). Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Data sources used for monitoring 16
4 Financial stability implications of fiscal measures The Working Group used the conceptual framework and available data sources to analyse the financial stability implications of fiscal measures from four perspectives. Section 4.1 describes the drivers of fiscal programmes and how these are related to the structure of the real economy and the financial system and their vulnerability to the pandemic. Section 4.2 focuses on the solvency and liquidity of borrowers and implications for credit markets and the solvency of the financial sector. Section 4.3 addresses the quality of balance sheet information, as it takes time for the vulnerabilities of borrowers to impact banks’ balance sheets. Section 4.4 considers the potential cliff effects related to the expiry of fiscal measures that warrant the attention of the authorities. 4.1 Drivers of fiscal measures Across Europe, governments have responded swiftly to the crisis, in line with the needs of their economies. Table 3 shows the uptake and announced size of the most important fiscal measures as at 30 September 2020. Macroprudential authorities reported government support packages related to the pandemic with a nominal value of more than €2,400 billion (around 14% of GDP) to the ESRB. This includes public guarantees on loans, public loans, direct grants and tax measures. By September 2020 the reported uptake of these programmes was over €700 billion (roughly 4% of GDP), with more than €400 billion of loans with public guarantees. In addition, more 11 than €840 billion of loans (around 5% of banks’ total loans) were subject to moratoria. 11 The total loans figure refers to September 2020 data from ECB CBD and BSI databases. There are methodological differences between these and the numbers published by the EBA with the reference date of June 2020 (which refer to data reported directly by banks). Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Financial stability implications of fiscal measures 17
Table 3 Announced size and uptake of moratoria and fiscal programmes (September 2020) Total size Total size Total size Total uptake announced Total uptake announced Total uptake announced (percentage (percentage (percentage (percentage (EUR billion) (EUR billion) of 2019 GDP) of 2019 GDP) of total loans) of total loans) Moratoria 838 5.0% 5.4% Public guarantees 435 1,580 2.6% 9.5% 2.8% 10.2% Public loans 66 57 0.4% 0.3% 0.4% 0.4% Direct grants 112 327 0.7% 2.0% Tax deferrals 77 170 0.5% 1.0% Tax relief 13 75 0.1% 0.4% Public support for credit insurance n.a. 227 n.a. 1.4% Total 1,541 9.2% Total w/o moratoria 704 2,436 4.2% 14.6% Sources: Recommendation ESRB/2020/08 (reference date 30 September 2020), ECB (MNA, BSI, CBD). Notes: Total size announced refers to field 1.1.01 and total uptake to field 2.2.10 for all measures apart from tax relief and tax deferrals, where field 2.2.12 was used. There are gaps in the data reported and results should be interpreted with caution, especially for the uptake of direct grants, tax measures and credit insurance guarantees, where reporting was not mandatory. For public loans, the total size announced is lower than total uptake owing to data gaps for the values reported by DE and PL. Total loans are taken from CBD and BSI databases. Beyond the broad and fast policy support, the exact measures taken differ by country. By 31 12 October 2020 more than 600 measures had been reported by the 31 ESRB member countries. 13 Chart 1 illustrates the heterogeneity in the scale and scope of measures across countries. The most common are public guarantees (used by all member countries), direct grants (used by 30), tax deferrals (29) and loan moratoria (23) (for more details, see Chart A). In terms of total uptake, 14 moratoria are used most extensively, followed by public guarantees and direct grants (Table 3). 12 The ESRB reporting templates cover seven distinct types of measure. However, the range of different types of programme across countries has been much wider. 13 In Figure 1, public guarantees and public loans are aggregated, because both directly increase the debt level of the borrower. As such, both feature the same economic mechanism when it comes to potential financial stability implications. Under the monitoring framework they are examined separately because they affect fiscal capacity differently. 14 Note that, for other measures, the absence of reporting on uptake might not necessarily mean they are not being used, just that member countries were not able to report it (these fields were also not mandatory). Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Financial stability implications of fiscal measures 18
Chart 1 Heterogeneity in the announced size and uptake of fiscal measures (percentages) Announced size Uptake 25 25 20 20 15 15 10 10 5 5 0 0 Public loans/ Direct grants Tax deferrals Public loans/ Direct grants Tax deferrals Loan moratoria guarantees guarantees Sources: Recommendation ESRB/2020/08 by 31 October 2020 (reference date 30 September 2020), ECB (MNA). Notes: Announced size (field 1.1.01) and uptake (field 2.2.10) as a percentage of 2019 GDP. The box plot shows the median, 25th and 75th percentiles (grey box), as well as the maxima and minima across countries for selected programmes. Announced size is not available for loan moratoria. Based on EU countries (IS, LI and NO are excluded). The qualitative survey of macroprudential authorities identified both liquidity and solvency 15 measures as important for providing support to NFCs and households. Across sectors in the real economy, moratoria (liquidity support) and direct grants (solvency support) are identified as the two most important measures for SMEs, large corporates and households. Public guarantees on loans and tax deferrals follow suit, with the former focusing on NFC vulnerabilities and the latter aiding households to sustain reduced income levels. Measures also differ across financial sectors. Moratoria and public guarantees are seen by macroprudential authorities as the measures having the most impact on banks, while direct grants were deemed to have most impact on the business of insurance companies and investment funds. In this case, there is an indirect impact on the financial system only through the effect of fiscal measures on holders of financial instruments. The immediate need for liquidity was an important driver of measures at the beginning of the pandemic. Liquidity support measures (moratoria, public guarantees on loans and public loans) are used in most countries. Also, the prompt introduction of public support for credit 16 insurance in many member countries helped to ensure that cross-border trade was not disrupted. While public guarantees are the most used fiscal programme in terms of announced size, moratoria have a higher uptake (see Table 3). It is worth noting, however, that in the case of moratoria there 15 As provided under template 3 of Recommendation ESRB/2020/08. Please see the Annex B for more details on the answers received by October 2020 with reference date 30 September 2020. 16 Credit insurance covers the risk that a trade partner does not pay (e.g. following bankruptcy or insolvency) or pays very late. Within this category, export credit insurance protects an exporter against the risk of non-payment or late payment by a foreign buyer. Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Financial stability implications of fiscal measures 19
is a broad dispersion of use across countries, and across banks within the same jurisdiction (Chart 2). Chart 2 Dispersion of the percentage of loans and advances under moratoria across countries and banks (June 2020) (percentages) IQR above median IQR below median 70 60 50 40 30 20 10 0 AT BE BG CY DE EE ES FI FR GR HR HU IE IS IT LT LU LV MT NL PL PT RO SE SI SK Sources: EBA, ESRB calculations. Notes: The chart shows the dispersion in loans under moratoria as a percentage of total loans and advances to households and NFCs across banks in a given jurisdiction. The boxes show the interquartile range (IQR): the median is where the box changes colour. The whiskers show the range between minimum and maximum values. While moratoria apply to both NFCs and households, public guarantees are mostly extended to NFCs. Supervisory data from June 2020 show that moratoria are widely used, but there is a broad dispersion of magnitudes across countries (Chart 2). For some countries, the use of moratoria is higher in household lending, although for most it is higher for NFCs and is especially pronounced for SMEs (Chart 3). With public guarantees it is clear that most of the support is extended to NFCs (Chart 4), although since these are granted as new lending, the impact on the 17 stock of loans is considerably smaller. Note, however, that the supervisory data refer to June 2020, when uptake of public guarantees was still modest, meaning that they might not provide a full 18 picture of their use. As at June 2020 public guarantees had been granted predominantly to loans to NFCs, which made up around €169 billion or 94% of all new loans subject to such schemes. The impact of public guarantees was also very uneven across European countries and banks. 17 According to supervisory data, the vast majority of these loans (98%) were newly originated. Only 2% were reported as restructured (i.e. loans not initially covered by the public guarantee and that were therefore restructured to become eligible). 18 Additionally, according to the EBA, implementation of the COVID-19 reporting guidelines has been delayed in some countries. For this reason, the percentage of loans subject to public guarantees might not have been reported. In addition, banks that use IFRS 9 may not report loans that are fully guaranteed in the first place, as they deem that the risks remain with the guarantor, i.e. the state. Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Financial stability implications of fiscal measures 20
Chart 3 Loans and advances under moratoria by sector (June 2020) (percentages of total loans and advances to the household, SME and NFC sectors) Households Non-financial corporations – SMEs Non-financial corporations – other than SMEs 70% 60% 50% 40% 30% 20% 10% 0% CY HU PT GR SI RO HR MT IT IS BG SK PL IE ES AT FR FI LV BE EE NL LT SE DE LU Sources: EBA, ESRB calculations. Notes: Countries are ranked by loans under moratoria as a percentage of total loans and advances to households, SMEs and NFCs. The values are the mean value for banks in a given country. Chart 4 New loans subject to public guarantees by sector (June 2020) (percentages of total loans and advances to the household and the NFC sector) Households Non-financial corporations 12% 10% 8% 6% 4% 2% 0% ES PT FR IT PL MT AT SI RO SK DE FI DK BE IE NL EE HR GR HU SE LV BG LU LT CY IS Sources: EBA, ESRB calculations. Notes: Countries are ranked by loans with public guarantees as a percentage of total loans and advances to households and NFCs. The values are the mean value for banks in a given country. The effects of the pandemic on the real economy are an important driver of the announced size of fiscal measures. The severity of the pandemic shock has varied greatly across countries and sectors. Together with pre-existing differences in the structural characteristics of the economies, this has led governments to adopt different packages. Chart 5 shows that countries which experienced a larger drop in GDP following the onset of the pandemic tended to announce Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Financial stability implications of fiscal measures 21
larger programmes and experienced a larger uptake of measures (hence the downward sloping line). The uptake of moratoria, public guarantees on loans and public loans is higher in these countries. Chart 5 Fiscal measures and GDP growth in the second quarter of 2020 (y-axis: size and uptake as percentages of GDP; x-axis: quarter-on-quarter GDP growth rate as percentages of GDP) Uptake, all measures Size, all measures 35% 30% 25% 20% 15% 10% 5% 0% -20% -15% -10% -5% 0% 5% 10% Sources: Recommendation ESRB/2020/08 by 31 October 2020 (reference date 30 September 2020), ECB (MNA). Notes: Announced size (field 1.1.01) and uptake (field 2.2.10) for all measures combined as a share of 2019 GDP on the y-axis. Quarter-on-quarter GDP growth from the first quarter of 2020 to the second quarter of 2020 on the x-axis. Based on EU countries (does not cover IS, LI and NO). Cross-country heterogeneity in economic structure is another important driver of the size and uptake of fiscal measures. There is a clear positive relation between the percentage of employment in vulnerable sectors and the uptake of state guarantees on loans, public loans, moratoria and direct grants. Also, economies with a larger share of employment in the sectors hit hardest by the COVID-19 shock had greater need for direct grants. Governments in these countries therefore tend to rely more on direct grants and less on public loans and guarantee programmes (Chart 6). Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Financial stability implications of fiscal measures 22
Chart 6 Fiscal measures and vulnerable sectors (percentages) Public guarantees and loans Direct grants Direct grants 12% 4% 4.0% 3% 3.5% 10% 3.0% Size of direct grants 3% 8% 2.5% 2% 6% 2.0% 2% 1.5% 4% 1% 1.0% 2% 0.5% 1% 0.0% 0% 0% 20% 25% 30% 35% Less vulnerable More vulnerable Less vulnerable More vulnerable Employment in vulnerable sectors sectors sectors sectors sectors Sources: Recommendation ESRB/2020/08 by 31 October 2020 (reference date 30 September 2020), ECB (MNA). Notes: Announced size (field 1.1.01) as a percentage of 2019 GDP on the y-axis for all three graphs. Vulnerability is defined as the percentage of employment in NACE sectors G, H, I R, T, U in the fourth quarter of 2019. The bar plots depict the median over the lowest (highest) quartile of the vulnerability metric as “less vulnerable” (“more vulnerable”). The scatterplot compares the announced size of direct grants (as a percentage of 2019 GDP; y-axis) to the vulnerability metric (a higher percentage means greater vulnerability; x-axis). All graphs are based on EU countries (but do not cover IS, LI and NO). Fiscal measures are also correlated with pre-crisis fiscal space. Countries with higher public deficits prior to the crisis tended to announce higher amounts of public loans and guarantees on loans (below-the-line measures) and use relatively fewer direct grants and tax measures. While an assessment of the fiscal impact of these measures is outside the scope of this report, it is relevant to note that policy choices can be influenced by fiscal space and that this fiscal space might also affect future vulnerabilities. Apart from total uptake, announcements of measures seem to have signalling effects. The mere announcement of guarantees may have helped to stabilise the bank lending market in the early stages of the crisis. So far, the uptake of public guarantees on loans has been relatively limited (Table 3). This may be due to reporting issues or administrative constraints delaying approvals or discouraging applicants. However, it is also possible that signalling effects have been at work. Chart 7 shows that countries which announced larger programmes of public guarantees on loans experienced stronger loan growth in the second quarter of 2020. Regressing bank lending growth in the second quarter of 2020 on the announced size and uptake of public loan and guarantees shows that the coefficient on announced size is highly significant, while the effect on uptake is insignificant. This may simply reflect the fact that schemes are channelled through the banking system, and the coefficient might also be picking up a variable that has been omitted. But it could equally indicate that the announcement of large-scale liquidity programmes improves funding conditions, possibly because of the confidence effect these create by reducing uncertainty and Financial stability implications of support measures to protect the real economy from the COVID-19 pandemic / February 2021 Financial stability implications of fiscal measures 23
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